SBA Advocacy Environmental Roundtable

***SBA Environmental Roundtable Meeting***

FRIDAY, APRIL 7, 2017 10 a.m. – noon


TO:                 Interested Persons


FROM:           Kevin Bromberg, Assistant Chief Counsel

        David Rostker, Assistant Chief Counsel

        Tabby Waqar, Assistant Chief Counsel


SUBJECT:     Next SBA Environmental Roundtable Meeting

The next U.S. Small Business Administration, Office of Advocacy Environmental Roundtable will meet to discuss the following topics, beginning at 10 a.m. on Friday, April 7, 2017.  The meeting will be held in Washington, D.C., at the Small Business Administration Headquarters, 409 Third Street SW, Eisenhower B Conference Room.  Send RSVP to  Please indicate whether you are attending in person, by webconference or by teleconference.  Information will be sent out to you when you RSVP.  We have adopted a casual attire option for all Roundtable meetings.


10:00 – 11 AM                   Methylene Chloride and N-Methylpyrrolidone; Regulation of Certain Uses Under TSCA Section 6(a)

Niva Kramek, Existing Chemicals Branch, Chemical Control Division, Office of Pollution Prevention and Toxics, EPA

11:00 – 12 PM                   Discussion: New Regulatory Reform Agenda (E.O. 13771 and E.O. 13777)


Roundtable meetings are open to all interested persons, with the exception of the press, in order to facilitate open and frank discussion about the impacts of Federal regulatory activities on small entities.   Agendas and presentations are available to all, including the press.  Anyone who wants to receive roundtable agendas or presentations, or to be included in the distribution list, should forward such requests to  The purpose of these Roundtable meetings is to exchange opinions, facts and information and to obtain the attendees’ individual views and opinions regarding small business concerns.  The meetings are not intended to achieve or communicate any consensus positions of the attendees.


Small Business Environmental Roundtable

Issues for Discussion

April 7, 2017


Methylene Chloride and N-Methylpyrrolidone; Regulation of Certain Uses Under TSCA Section 6(a)

On January 19, 2017 EPA published a Toxic Substance Control Act (TSCA) Section 6(a) proposed rule to regulate certain uses of methylene chloride and n-methylpyrrolidone (NMP).  EPA proposed a determination of unreasonable risk for methylene chloride and NMP use in paint and coating removal.  The proposal includes a prohibition on the manufacture (including import), processing, and distribution in commerce for consumer and commercial uses for both chemicals.   The proposed rule also includes a prohibition for these commercial uses of both chemicals, including downstream notification and recordkeeping requirements.  The agency’s proposal provides a ten-year limited exemption for coating removal uses of both chemicals critical for national security and an exemption for methylene chloride use in commercial furniture refinishing.  The agency has also provided an alternate proposal to regulate NMP, which includes a requirement to establish a worker protection program for commercial use and a limit of 35 percent NMP for processors of paint and coating removal products.

EPA has prepared an initial regulatory flexibility analysis under the Regulatory Flexibility Act, examining the impacts of the proposed rule on small entities.  EPA also convened a SBREFA panel to consider the impacts of the proposed changes on small entities in 2016; the panel report is in the docket.  The comment deadline for the proposed rulemaking is April 19, 2017.

New Regulatory Reform Agenda

As indicated on the agenda, for the second hour, we plan on discussing the new regulatory reform agenda emanating from Executive Order 13771 (Reducing Regulations and Controlling Regulatory Costs, i.e., “1 in 2 out”), Executive Order 13777 (Enforcing the Regulatory Reform Agenda), and other White House directives.  We are particularly interested in hearing from you about which regulations you think should be prioritized for review and reform.


The Office of Advocacy invites all small businesses and their representatives to present their perspectives as well.  To reserve a spot on the agenda, please contact Tabby Waqar at